Subject: File No. S7-14-08
From: James Kerstein

September 10, 2008

I believe that indexed annuities are 'fixed rate" annuities. And since they have a guaranteed minimum interest credit also no risk for loss of principal, they
offer a safe viable alternative.

I believe the state insurance departments are doing a good
job of regulating suitability,disclosure advertising,agent training, enforcement of penalties for
any non-compliance.

Also, guaranteed minimum values are already regulated through the Standard Nonforfeiture laws applicable to annuities.'

Even in a declining DJIA of 20% since 10/07, a fixed "indexed" annuity purchaser will not lose any principal due to market performance.